MFA submitted comments to the European Securities Markets Authority on its consultation paper on Guidelines on certain aspects of the MiFID compliance function requirements. In our letter, we highlighted that: (i) In the case of an investment firm which is part of a corporate group, it may be appropriate to have a centralized compliance function situated within another group entity; (ii) Compliance officers should not be required to have formal compliance or legal qualifications, provided that they have a good knowledge of the regulatory system combined with a thorough understanding of the business carried out by their investment firm gained through relevant experience. This is particularly important in the context of a corporate group with a centralized compliance function where the chief compliance officer for the group may be based in a jurisdiction outside of the EU; (iii) It should be left to the investment firms discretion to decide which types of functions may be combined with the compliance function; and (iv) ESMA should clarify which types of external compliance services may amount to outsourcing of the compliance function.